MLRO Protection & Judgement Training

Recognise the pattern
before your organisation becomes the next case study.

Most compliance training teaches the rules. Kim teaches why organisations with the MLRO in place, the written policy on file and the audit committee signed off still failed — built on real enforcement cases across banking, payments and crypto-exchange compliance. Available 24/7. Free to evaluate.

76+
Real enforcement cases and technical references, growing weekly
4
Sectors covered — banking, local government, sports governance, crypto exchanges
24/7
Kim is available whenever you need her
The Challenge

Why compliance functions fail despite having compliance

📖

Rules are not the same as judgement

Knowing the definition of Enhanced Due Diligence does not tell you what to do when a plausible explanation is in front of you and something still feels wrong. Most training stops at the definition.

⚠️

The MLRO was in place. It still happened.

Real enforcement cases repeatedly show the same pattern — an organisation with a written policy, a compliance officer and an audit committee, and no one testing whether it actually worked in practice.

⚖️

Personal liability has changed, not just firm liability

Under the Economic Crime and Corporate Transparency Act 2023, what can be pinned on an individual MLRO or compliance officer is materially different. Generic training rarely covers what actually protects the person in the role.


How Kim Works

Pattern recognition.
Not memorisation.

Kim doesn't open with a definition and quiz you on it. She opens with a real situation — a customer relationship, a settlement pattern, a founder's own words used against them in court — and makes you reason through it before revealing the principle. That is the judgement senior compliance roles actually require.


Whether you are an MLRO protecting your own position, a compliance officer moving into a senior role, or a team leader onboarding into VASP and crypto-exchange risk, Kim adapts to where you are and focuses on the pattern, not just the checklist.


Beyond exam prep: live decision support mid-transaction, NED and audit committee briefings, MLRO handover continuity, bespoke due diligence document generation, and emerging use in insurance and fintech-partnership risk.


Try Kim — No Account Required
  • 🎯

    Real cases, not quiz questions

    Kim works through actual enforcement cases — Wirecard, Greensill, Binance, FTX, BitMEX — not hypothetical scenarios. The reasoning that failed in each case is the reasoning she teaches you to catch.

  • 🔄

    The same pattern, every sector

    Wilful blindness and captured oversight repeat across banking, local government, sports governance and crypto exchanges. Kim teaches the underlying pattern, which transfers wherever your career goes next.

  • Instant, detailed responses

    Kim explains her reasoning, not just the answer. Ask follow-up questions, challenge her thinking and push into the detail.

  • 🔒

    No account. No personal data. No risk.

    Kim requires no registration. No name, email or identifying information is ever collected. Conversations are not stored or retained.


Beyond Exam Prep

Six more ways compliance teams put Kim to work

Live decision support

Mid-transaction, mid-onboarding, mid-review: ask Kim about the actual scenario in front of you and get a reasoned view in the moment, not a training memory from six months ago.

📋

NED and audit committee briefings

Prepare non-executive directors and audit committees for the AML-specific questions they should be asking management, translated out of compliance jargon.

🔄

MLRO handover continuity

When an MLRO leaves, the organisation's institutional memory of past decisions and known risk areas often leaves with them. Kim gives an incoming MLRO a queryable record to interrogate from day one.

📄

Bespoke due diligence documents

Generate a fully cited, statute-grounded onboarding or vetting questionnaire for a specific customer type or contract on demand, not a generic template.

🔍

Post-incident retrospectives

After a near-miss, run a structured lessons-learned session tied to the closest real enforcement case in Kim's knowledge base.

🏦

Insurance and fintech-partnership risk

An underused adjacent vertical: claims fraud typologies, high-value-line underwriter PEP training and reinsurance counterparty due diligence.


Introducing Reeve

Built for Officers that sign off on public money.

Section 151 Officers and procurement staff inside councils and public bodies, where the personal exposure runs through different statute entirely: the Local Government Finance Act 1988, the Procurement Act 2023, the Bribery Act.


Same underlying discipline — real cases, real statute, judgement over memorisation — built around the specific law a council officer is actually exposed to, not a financial-services curriculum with the names changed.


Beyond training: live procurement and treasury decision support, Annual Governance Statement drafting, interim officer handover continuity, and bespoke supplier due diligence questionnaires — built for the exact moments an S151 or procurement officer's exposure is highest.


Try Reeve — No Account Required
  • 🏛️

    Section 151 Officers

    The personal, non-delegable duty under s114 LGFA 1988 to report unlawful spending — worked through against real collapses like Thurrock, not abstract theory.

  • 📋

    Procurement Officers

    Procurement Act 2023 thresholds and aggregation rules, direct-award and lot-splitting red flags, and exactly where the Bribery Act and Fraud Act attach to a named decision.

  • 🧮

    Treasury "Trust But Verify" calculator

    A real deterministic calculator for checking a broker's loan or option quote against what a council could borrow directly from central government — Reeve narrates the result, never guesses the maths.

  • 🔒

    Its own sealed instance per organisation

    Not a shared chatbot with a logo swapped — each council or public body gets infrastructure that belongs to that instance alone.

Reeve — S151 & Procurement

Croydon Council — Brick by Brick and the £1.6 Billion Collapse

A council-owned property company that built three homes in eleven years on £200m of borrowed money, an uncompeted £73m arts venue refurbishment, a Section 151 officer who was also the company's own first director, a planning-committee chair married to the cabinet member overseeing the scheme, and the 2000 and 2010 abolitions that removed the two mechanisms that might have stopped it sooner. No criminal charges followed.

Read the Article
Reeve — S151 & Procurement

What Westminster's Digital Government Report Means for Council Procurement

HC 61 — the Commons Science, Innovation and Technology Committee's "Rewiring the state" report — is nominally about Whitehall. Three of its four barriers to digital transformation are council procurement problems in exactly the same shape: vendor lock-in, legacy systems and sovereignty. Covers the £330m NHS Federated Data Platform, the £472m AWS/HMRC sole-bidder contract, and the capital-versus-resource budgeting problem under s114.

Read the Article
Reeve — Training Masterclass

Procurement Masterclass: What "Rewiring the State" Means for Council Procurement Officers

The companion training piece to the HC 61 briefing — five modules built for direct use in a session with Section 151 and Procurement Officers, with a suggested masterclass structure, a break-clause exercise, and slide-ready figures.

Read the Article
Kim — PEP & Regulatory Capture Reeve — Procurement Red Flags

Manufactured Consensus — Inside Britain's Lobbying, Legal and Procurement Underworld

A small, overlapping cast of lobbying firms, PR agencies, litigation funders and revolving-door officials working to manufacture the appearance of independent consensus — in newsrooms, courts, think tanks and the public procurement decisions that follow. Covers CT Group, the Lodhia litigation-fabrication case, IEA/Templeton Foundation funding opacity, and the Palantir NHS/MOD contracts via Peter Mandelson's undeclared Global Counsel stake. Relevant to both products: a PEP-shaped risk for Kim, a live procurement red-flag case study for Reeve.

Read the Article
Kim — Wilful Blindness Series

The Promise and the Pattern — UBS Recidivism, 2000–2026

Twenty-six years of AML and tax-compliance recidivism at one bank: a 2000 IRS agreement broken almost immediately and exposed by a whistleblower in 2007 ($780m DPA in 2009), and a 2018 FinCEN finding on FX wire monitoring that recurred, unremediated, into a $125m fine in 2026 — the largest-ever BSA penalty against a broker-dealer. Introduces the reusable "Promise-Practice Gap" framework for any compliance commitment in any firm.

Read the Article

Case Studies

Real cases. Real failures. Real lessons.

Each of these organisations had a compliance function on paper. Each report analyses what actually happened, why the controls didn't work in practice, and the pattern every MLRO and compliance officer should learn to recognise before it repeats.

Case Study 01

Trafigura v Gupta — The $600 Million Nickel Fraud

How a commodity trader sold $600 million in worthless nickel cargoes to one of the world's largest trading firms — and concealed the proceeds across four jurisdictions. Eight lessons for AML compliance teams.

$600M
Fraud value
8
Compliance lessons
5
Scenario exercises
Read the Report
Case Study 02

Greensill Capital / Credit Suisse — The $10 Billion Compliance Collapse

How Credit Suisse channelled $10 billion of client money into a supply chain finance firm — ignoring four years of internal warnings, performing no independent credit assessment and allowing a circular funding structure to grow unchecked.

$10B
Client money
10
Compliance failures
5
Scenario exercises
Read the Report
Case Study 03

Archegos Capital / Bill Hwang — The $160 Billion Leveraged Deception

How a convicted fraudster used total return swaps to secretly accumulate $160 billion in leveraged exposure — lying to nine prime brokers, manipulating market prices for a year and triggering one of the fastest destructions of institutional wealth in financial history.

$160B
Peak exposure
10
Compliance failures
18 yrs
Prison sentence
Read the Report
Case Study 04

Woodford Investment Management — When the Star Becomes the Risk

How the UK's most celebrated fund manager suspended £3.7 billion of retail investor savings — gaming UCITS liquidity rules via a Guernsey listing mechanism, while the ACD, regulator and UK's largest retail platform each chose deference over challenge. Zero individual sanctions under SM&CR.

£3.7B
Assets frozen
10
Governance failures
0
Individual sanctions
Read the Report

Compliance Framework Papers

Structural analysis for compliance professionals

Deep-dive framework papers examining the systemic conditions that allow financial and regulatory misconduct to persist. Written for MLROs, compliance directors and risk professionals.

Framework Paper 01

When Compliance Isn't Enough — Conflicts of Interest and Elite Regulatory Capture

How sophisticated networks of former officials, advisory firms and corporate clients operate legally below the regulatory waterline — gaming the Lobbying Act, exploiting ACOBA's lack of enforcement, and structuring NHS, MOD and Civil Service contracts to land with the same players every time. Includes a dark examination of redacted government contracts, council technology catastrophes and the lawyers who draft the secrecy in.

5
Structural gaps
4-step
Detection framework
5
Training scenarios
Read the Report
Framework Paper 02

The Captured Watchdog — Auditors, Advisers and the Compromised Inner Circle

How the structural conflicts at the heart of the Big Four audit model, the revolving door advisory market and AI-assisted compliance are converging to eliminate individual accountability — and why plausible deniability can no longer cloak systematic law-breaking. Covers KPMG Australia, the Mandelson/Palantir/OpenAI procurement questions, Purnell/Flint Global/Cinven and the German AI liability rulings of 2026.

9
Sections
8
Training scenarios
6
Reform recommendations
Read the Report

Special Reports

Deep analysis — where markets, law and compliance intersect

Long-form analytical reports examining structural compliance questions at the frontier of market regulation. Written for senior compliance professionals, MLROs and risk directors.

Special Report — June 2026

The Dangers of Index Inclusion: The SpaceX Conundrum — Nortel Networks and the Passive Investor's Trap

A 17-page compliance masterclass examining the structural risks created when a restricted-float IPO triggers mandatory index buying at extreme valuations — traced from Nortel's collapse at 35% of the TSX 300 to SpaceX's $2.1 trillion listing with a 5% public float. Covers MAR Articles 7, 8 and 12, UCITS concentration limits, the Nasdaq-100 float-scaling methodology, SEC float waiver, FCA COBS obligations, MiFID II conflicts and the accountability vacuum left by fragmented global regulation. Includes 8 training scenarios, an MLRO checklist and analytical guidance on when the structure may engage market manipulation provisions.

17
Pages
8
Training scenarios
4
Regulatory frameworks
MAR 7/8/12
Key provisions
Read the Report

What Kim Covers

Technical grounding and applied judgement, together

Every technical topic a compliance role requires — taught through real cases, not isolated definitions.

MLRO personal liability and ECCTA 2023
AML red flags and financial crime typologies
KYC, CDD and EDD requirements
Sanctions screening and PEP monitoring
Suspicious activity reporting (SAR)
FATF recommendations and standards
UK, EU, US and APAC AML frameworks
Enterprise-wide risk assessment
Correspondent banking and de-risking
VASP and crypto-exchange compliance
Trade-based money laundering
Beneficial ownership and corporate structures

Who Uses Kim

Built for compliance professionals

Compliance Officers

Working at payment institutions, EMIs, banks and fintech firms preparing for AML certification for the first time or at renewal.

MLROs and Deputies

Money Laundering Reporting Officers who need documentation and judgement that would survive scrutiny — not just regulatory knowledge for its own sake.

Legal and Accountancy

Solicitors, accountants and professional advisers subject to AML obligations under the Money Laundering Regulations 2017.

Fintech and Banking

Front-line staff, onboarding teams and risk professionals at regulated firms who need a deeper understanding of AML obligations.

Payments and Crypto Exchanges

Professionals at payment service providers, e-money institutions and VASPs — with case studies drawn from Binance, FTX and BitMEX, not generic KYC theory.

Training Providers

Organisations that want to white-label or integrate Kim into their own compliance training programmes. Licensing available.

Privacy and Data

No account. No personal data. No risk.

Kim requires no registration and asks for no personal information. No conversation content is retained. Kim records only anonymous session data — your country, your selected role and your study goal — solely to improve the service. No name, email address or identifying information is ever collected. Kim is operated in accordance with UK GDPR and the Data Protection Act 2018. ICO Registration: C1901798.

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Try Kim

No account. No credit card. No commitment. Kim is free to use for evaluation. Commercial deployment, white-labelling or integration into your own platform requires a licence from Netizen9.